3EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9445.04-84
TITLE: EPA-Approved Waste Analyses Test Methods
APPROVAL DATE: n/19/84
EFFECTIVE DATE: n/19/84
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
STATUS:
REFERENCE (other documents)
[ ] A- Pending OMB approval
[ ] B- Pending AA-OSWER approval
[ ] C- For review 4/or comment
[ ] D- In development or circulating
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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. ^^ Washington. DC 20460
V>EPA OSWER Directive Initiation Reauest
Originator r.;er.n, 0>i»...:..c \»tr.i,er
9445.04-84
moer
Date
i
Title
EPA-Approved Waste Analyses Test Methods
Summary of Directive
EPA-approved waste ananlysis test methods are found in SW-846.
Applicants that want to use special test methods not previously approved
by EPA must obtain EPA approval prior to including it in the waste analys
plan. Additional methods for analyzing petroleum wastes are described
seperately.
Key Words :
Test Methods
Type of Directive iManual. Policy Directive. Announcement, eic.i ' Status
O Draft
. - O Final
i U New
1 LJ Revision
Does this Directive Supersede Previous Directivels;' [_J Yes [_J No Does It Supplement Previous Directive^!' £] Yes [_] No
If "Yes" to Either Question. What Directive /number, title)
Review Plan
D AA-OSWER D OUST D OECM D Other iSpecity)
D OERR D OWPE D OGC
yD OSW D Regions O OPPE
Request Meets OSWER Directives System Format
signature of Lead Office Directives Officer
Signature of OSWER Directives Officer
] Date
|Date
LS
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NOV I 9 198/1
MEMORANDUM
SUBJECT* RCRA Part B Permitting Questions
from Exxon Company, Billings, Montana
FROMt Bruce R. Weddle
*> Director
«-• Permits and State Programs Division (WH-563)
x
|> TOt Robert L. Duprey
c Director
Air and Hazardous Materials Division, Region VIII
e I am writing in response to the questions from Exxon Company
*js conveyed in your September 25, 1984, memorandum. The issues are
£ addressed in the sequence that they were presented. Please
*» contact Rich Steimle, 382-4754, for additional information or
oj clarification.
« 1) Section 264.272(a) requires the owner or operator of a land
o treatment unit (LTV) to demonstrate that hazardous constituents
£ in the waste can be completely degraded, transformed or immobi-
oo liied within the treatment cone. The intent of this 'complete*
«• treatment demonstration requirement is to ensure that during the
^ demonstration sufficient data are generated to predict that
r-« haxardous constituents can be treated at the proposed unit.
£*, 'Total degradation need not be achieved during the limited time
JC\ of the demonstration. However, the rates of these mechanisms
•*<* must be calculated so that it can be predicted that treatment
(!I^H will be complete within the treatment sone.
00
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2) Sections 270.20(b)(4) and 264.271(b) require the applicant
to list and analyze for all the Appendix VIII constituents
reasonably expected to b
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6) In response to the first part of this question, the ranking
of hazardous wastes in support of land disposal restrictions
will be determined on the basis of information beyond just land
treatment results, since the restrictions will apply to all
forms of land disposal. However, land treatment demonstration
data may be used in the overall determination of which wastes
will be banned. Since the restrictions program has not been
made final and depends on recently enacted RCRA amendments, a
detailed rationale for ranking wastes has not been developed.
In response to the second question, the new RCRA amendments
define land treatment as a method of land disposal and subject
to restriction. It is possible that a land treatment facility
could receive a permit after a treatment demonstration* only
later to have it modified or revoked by enactment of general
land disposal restrictions ($270.4Kb) (1) and §270.43(a) (3)).
The new RCRA amendments do, however* allow an owner or
operator to petition the Administrator to allow continued disposal,
if it is demonstrated, to a reasonable degree of certainty* that
there will be no migration of such constituents from the disposal
unit or injection zone for as long as the wastes remain hazardous.
Hence* certain land treatment facilities may be allowed to continue
disposal of a generally restricted waste.
7) The draft guidance manual for land treatment demonstrations*
which soon will be released for public review* details the
information requirements for issuance of a two-phase permit.
Before drafting a two-phase permit* the permit writer must have
a clear understanding of the waste characteristics* treatment
zone characteristics (soil moisture, soil pH, soil texture*
CEC), local climate* operating practices* hydrogeology* and
groundwater quality. He must also have substantial information
concerning degradation of the waste* accumulation in soil of
non-degradables* leaching hazards* acute toxicity and chronic
toxicity of the biomass*
8) Appendix VIII may be expanded next year* and it is likely
that an expansion would include additional constituents in oil
refinery waste. Haste analysis for additional petroleum waste
constituents may* therefore* be required.
9) EPA proposed analytical screening procedures'for Appendix
VIII constituents in the Federal Register on October 1* 1984.
A final rule is planned for publication by the end of 198S.
10) The 90-day and 180-day time frames are parallel* hot in
sequence. EPA does not believe that permit issuance should be
unreasonably delayed to allow an applicant to begin to collect ,
data necessary for an ACL showing (July 26, 1982* 47 PR 32307).
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The applicant should begin planning an ACL demonstration early
if he wishes to be considered for the variance available in
§264.94(b). Applicants not attempting an ACL demonstration for
all Appendix VIII constituents of concern must promptly submit
a corrective action feasibility plan. This plan is an initial
assessment of corrective action options which the applicant
should be able to produce within the 180-day time frame provided*
11) If downgradient water quality is improved through a successful
corrective action plan, the facility may return to a compliance
monitoring program through a permit modification. This is to
ensure that hazardous constituents identified during corrective
action do not reappear In groundwater after corrective action
has ceased. EPA has not yet developed a policy regarding possible
reversion to a detection monitoring program.
12) The major reasons for the one meter separation requirement
were described in 47 PR 32326 (July 26, 1982). They include the
following}
(a) to prevent saturation of the treatment zone which
inhibits treatment;
(b) to prevent wastes from being saturated and in direct
contact with groundwater;
(c) to allow for successful operation of unsaturated tone
monitoringi and,
(d) to take into account fluctuations in the seasonal high
water table (SHWT) and Inaccuracies in determining the SHUT*
In addition, the maintenance of the SHWT at 1 to 3 meters
below the treatment xone correlates well with optimal coil
moisture conditions in the treatment zone and with favorable
soil surface conditions necessary to allow site access by heavy
equipment*
13) EPA supports the use of soil water measuring devices
including lysimeters. A contractor report on the evaluation of
soil poreliquid monitoring devices was recently completed and
is attached for your information; EPA is currently considering
the recommendations in this report.
A draft guidance document on Unsaturated Zone Monitoring
was issued last year. A revision of this document should be
available to the public soon* Additional reasearch studies
concerning soil pore and soil core monitoring are continuing
and the results are not yet available.
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REPERENCES USED
1. B.P.A., Test Methods for Evaluating Solid Waste (SW-846),
1982
2, E.P.A., Unsaturated Zone Monitoring for Hazardous Waste
Land Treatment 'Units/ (Draft), June, 1983
3. E.P.A.* Hazardous Waste Land Treatment Demonstration,
(Draft), 1984
4. E.P.A., Handbook for the Analysis of Petroleum Refinery
Residues and Waste, (Draft) April, 1984
Attachments
cc: Jack Lehraan
Eileen Claussen
Peter Guerrero
Hazardous waste Division Directors* Regions I-VII, IX-X
(with incoming)
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